Economía circular en el Derecho de la Unión: ambición y realidad desde un enfoque comparado entre Italia y España

The purpose of this paper is to provide a legal analysis of the implementation of the circular economy paradigm in European Union law, with a comparison between Italy and Spain. Starting from the European strategic framework, it examines how both countries incorporate the principles of the circular economy into their national legal systems, with special attention to institutional and constitutional architecture, as well as administrative capacities. Although they show normative convergence with the EU framework, they face common challenges in institutional capacity, territorial cohesion, and citizen participation. The study argues that the circular economy represents a structural transformation that requires institutional cooperation, democratic participation, and cultural adaptation. It concludes that EU law must indeed integrate and harmonise, but taking territorial diversities into account. Overcoming challenges such as regional disparities and participation deficits demands effective multi-level governance and a flexible interpretation of EU law to achieve a just and democratic transition.